Is there a set timeline for FCA applications?

One of the most common questions we receive is about FCA application timelines, specifically, how long firms can realistically expect their applications to take

According to FCA data between October and December 2024, new firm authorisations had an average processing time of 110 days. Securing FCA authorisation can be a complex process, and timelines are often unpredictable. While the FCA aims to decide within six months of receiving a complete application, many cases take 12 months or more to be resolved. Delays are commonly caused by missing documentation, unclear business models, or governance concerns.

Here are a few guidelines on factors that may impact FCA application timelines as well as steps you can take now to avoid avoidable delays. Our expert financial services solicitors provide tailored, up-to-date guidance to help you submit a strong, complete application and navigate the process efficiently.

What happens after you apply?

Once submitted, the FCA will carry out an initial check to determine whether your application is complete according to its authorisation process. If it isn’t complete, the review won’t begin until all required documents and information are provided.

Once the application is deemed complete, the review window starts. You’ll be assigned a case officer who will review your submission and likely come back with follow-up questions or requests for clarification. This back-and-forth can continue for weeks or even months, depending on the complexity of the business and the quality of the original application.

It’s important to understand that the FCA clock only runs when the application is “in progress.” If they’re waiting for you to respond to a query, the timeline pauses.

What slows things down?

Most delays come from authorisation applications that don’t meet the FCA’s expectations the first time around. The most common issues include:

• Incomplete or inconsistent documentation
• Unclear governance structures or business models
• Concerns around the fitness and propriety of individuals in senior roles
• Demonstrating that the applicant’s ‘mind and management’ is based in the UK
• Lack of detail on financial resources or compliance arrangements
• Business models involving higher-risk activities, like payments or crypto, may prompt deeper scrutiny

The FCA may come back with several rounds of questions, and each one adds time. In some cases, the FCA may suggest withdrawing the application (rather than proceeding to a refusal).

What happens if the FCA isn’t satisfied?

If your application doesn’t meet expectations, then the FCA can refuse it. Even where they don’t reject it outright, the FCA may raise issues that delay the process significantly.

A refusal decision notice may be published on the FCA’s website, which would become a matter of public record and can affect your reputation, as well as your ability to apply again in future. So, it’s better to delay submission and strengthen your application than to prioritise pace over completeness, thereby minimising the risk of an unsuccessful application.

Navigating FCA authorisations

The FCA application process is complex, involving detailed scrutiny of your business model, governance, and compliance arrangements. While the FCA aims to assess complete applications within six months, there’s no guaranteed timeframe. For many firms, especially those with incomplete or inaccurate submissions, the process can extend to 12 months or more.

With extensive experience advising clients and a background working within the Financial Conduct Authority, our financial services solicitors bring both regulatory insight and commercial acumen to help you navigate the process with clarity and confidence.